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September 20, 2021

Introduction

The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7814), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

Wave 23 for FY 2021 was released on Thursday, September 16th, for a total of $29.0 million.  Cumulative commitments are $2.19 billion.  Nationwide, USAC has now funded 94% of the FY 2021 applications representing 76% of the requested funding.

The first 2021-2022 application window for the Emergency Connectivity Fund (“ECF”) closed Friday, August 13th.  Applications received during the window totaled over $5 billion.  An additional two-week 2021-2022 ECF application window will open September 28th (see our newsletter of August 30th).

Last week (actually September 10th), USAC posted the long-awaited ECF Form 471 dataset that can be viewed online or downloaded for analysis.  The full dataset is available as a large Excel (or alternative format) spreadsheet listing every application (including out-of-window applications) submitted for the first ECF window.  Each row of the dataset represents one FRN line item with 79 data elements.  Some of the more important data columns are listed below.

Col     Description
A Application Number in the form ECF2021xxxxxx
C URL link to the PDF version of the application
G Applicant Name
M Billed Entity Number (“BEN”)
Applicant Subtype
Q Consulting Firm (if applicable)
AH  Total Funding Commitment Request Amount (for all line items in application)
AJ Window Status (In Window or Out of Window)
AM  Funding Request Status (currently all “pending”)
AO Service Type (Equipment or Services)
AQ Service Provider Name
AU Invoicing Method (Applicant or Service Provider)
BK Product Type
CA Total Line Cost

One aspect of the spreadsheet that is a little confusing, at least at first glance, is that it repeats a total application funding request amount (Col. AH) on each line item row for that application.  Similarly, it repeats a total FRN funding request amount (Col. AZ) on each line item row for that FRN.  For example:

ECF Form 471 Dataset

The data shown is for a single application with two FRNs (Col. AL).  The first FRN shown has two line items, each on a separate row.  The total requested amount of the application, repeated in all three rows of Col. AH, is the sum of the individual line item amounts in Col. CA.  Similarly, the total request for the first FRN, repeated in the first two rows of Col. AZ (with breakdowns for recurring and one-time charges) is the sum of the two line item amounts in Col. CA.

Col. CA is particularly important because its summation indicates total demand.  This figure is critically important in determining the maximum possible ECF second window allotment.  USAC had previously reported the total ECF demand at $5.137 billion.  Analysis of the dataset clarifies that this figure is the total requests for in-window applications only.  It does not, however, take into account that many applicants requested amounts greater than the $400 cap per connected device on their Form 471.  In over 2,200 FRNs, the sum of the costs in excess of the $400 cap is approximately $270 million.  Adjusting for this excess alone would reduce the initial demand to $4.867 million and would restore over a quarter of a billion dollars for use in the second window.

Although we don’t expect many changes in the dataset numbers until USAC starts issuing Funding Commitment Decision Letters (“FCDLs”), or perhaps Wave Ready indications, please note that the dataset is periodically being updated.

Hint on dataset usage:  To download the complete dataset as an Excel file, go to the ECF Form 471 dataset homepage, click “Export”, and choose “CSV for Excel.”  To increase readability, we suggest immediately resetting all row heights to 15.

ECF Form 471 dataset homepage

Upcoming E-Rate Dates:

September 23       Form 486 deadline for FY 2020 covering funding committed in Wave 56.  More generally, the Form 486 deadline is 120 days from the FCDL date or from the service start date (typically July 1st), whichever is later.  Upcoming Form 486 deadlines are:
Wave 57            09/30/2021
Wave 58            10/07/2021
Wave 59            10/14/2021
Wave 60            10/21/2021
September 27 Due date for initial comments on the FCC’s draft version of the Eligible Services List (“ESL”) for FY 2022 (DA 21-1062).  Reply comments are due by October 12th.
September 28 Opening of the second ECF application window for 2021-2022.  This shorter 15-day window closes October 13th.
September 30 General non-recurring service delivery deadline for FY 2020 and, under the FCC’s COVID extension, for FY 2019.
October 20 Nomination deadline for six USAC Board members including one school representative.  The FCC subsequently added a request for board member nominations representing commercial mobile radio service providers (due November 8th).

USF Quarterly Contribution Factor for 4Q21:

The FCC announced that the Proposed Fourth Quarter 2021 Universal Service Contribution Factor will be 29.1% (see DA 21-1134).  As shown below, this is below the 2Q21 high of 33.4%, but still uncomfortably high.

USF Quarterly Contribution Factor for 4Q21

A recent report, entitled USForward, was released this month by the Schools, Libraries & Healthcare Broadband (“SHLB”) Coalition, INCOMPAS and NTCA-The Rural Broadband Association.  The report focuses on declining revenues in the Universal Service Fund (“USF”) contribution base.  Warning of a 40% contribution factor by 2025, the report makes a case for adding broadband internet access service revenues to the base, a move that it projects could reduce the contribution factor to under 4% and stabilize the Fund.

Separately, FCC Commissioner Brendan Carr highlighted an alternative study, also pointing to the USF funding problem, but recommending an alternative service fee on digital advertising services.  One way or another, an additional source of USF funding is desperately needed — and soon!

USAC’s Emergency Connectivity Fund Program Newsletter of September 14, 2021, discusses the following topics:

  • The recent launch of the ECF Form 471 dataset (covered in greater detail above).
  • A warning that incomplete Form 471 applications generated during the first ECF application window will be cancelled in advance of the opening of the second window on September 28th.
  • A reminder that service providers have access to the ECF Portal through their OnePortal dashboards.

The ECF newsletter also addresses the following additional frequently asked questions:

Are taxes included as part of the $400 maximum for connected devices?
Short answer: No.  This is confirmation of a recent update in USAC PIA procedures discussed in our newsletter of September 6th.

After submitting an application during the first application filing window, a school or library realizes they need additional equipment and services to meet their students’, school staff’s, or library patrons’ unmet needs.  Can the school or library submit another application during the second window to address these unmet needs?
Short answer: Yes (but avoid duplicate requests).

How will requests be prioritized?
Short answer: Higher discount applicants will be funded first if second window requests exceed the ECF funding cap.

If a school or library submitted an application during the first application filing window and has not heard from USAC on their funding request by the time the second application filing window opens (e.g., September 28, 2021), should they re-apply for funding in the second window?
Short answer: No.

I applied during the initial application filing window and I'm still waiting to hear back about my application.  Is there anything else I should be doing now?
Short answer: Check DUNS, FCC RN, and SAM.gov registrations.

If I have the credentials to access the ECF Portal, can I begin filling out my application for the second application filing window before the window opens?
Short answer: No.

Will I have visibility in the ECF Portal for the committed version of my application?
Short answer: Yes.

Will I receive a notification when the PIA reviewer contacts me about my application?
Short answer: Yes (if full rights user).

I can access the ECF Portal, but can’t file any forms – what can I do?
Short answer: Ask your account administrator to upgrade to a full rights user.

If the service provider is invoicing on behalf of the applicant, does it need a SPIN for ECF?
Short answer: Yes.